Recommendation:
The Army and Air National Guard operate under the control of the federal government, with very few exceptions. Therefore, the NG should have the same access to DERA funding as their active duty counterparts for ALL contaminants for the purposes of investigation, design, remediation and all related peripheral costs. Based upon the Policy put forth by the Assistant Secretary of Defense for Energy, Installations and Environment memo dated 28 Nov 2017, the NG was retroactively eliminated from using DERA funds. Since that memo, NDAA FY19 has allocated $29M for Guard use for at PFOS/PFOA contaminated site remediation, in addition to opening up DERA funded for NG PFOS/PFOA investigation and design. Those two compounds are but two of the contaminates that require remediation when discovered on NG facilities. This policy eliminated Guard use of DERA funds for any legacy or emerging contaminants. If the Guard is no longer allowed DERA funding, they must now use O & M funds for these “must pay bills”. Basically, this would require the National Guard to utilize operational funds normally slated for maintenance and training; dramatically affecting unit mission readiness and lethality of the force.